The mistake: assuming no TUR plan is required for a chemical because your company didn’t exceed the reporting threshold in two consecutive years.

TUR plans or plan updates are due to be completed by July 1st on even years (2014, 2016, 2018 etc.). The year in which the plan is due is referred to as the Planning Year by the TURA planning guidance . The TUR plan must include each TURA listed chemical that is being reported on for use during the calendar year prior to the Planning Year (plans due July 1, 2018 reference chemical use during calendar year 2017) and that was also reported at least once more for any additional calendar year prior to the Planning Year. 

Therefore, if a facility is reporting on the chemical for the first time in the Planning Year, no plan is required for that chemical. However, facilities should be sure to check their records. This two year use rule counts for any year prior. Plans due by July 1, 2018 must include all chemicals used above threshold both in 2017 and in any year prior when that chemical was subject to TURA filing (not just 2016 and 2017).

The mistake: deciding not to plan without seeking the appropriate exemption.

If you think your facility may be eligible for an exemption from planning this year, we recommend checking with your TUR planner, MassDEP, or with OTA. See pages 8 and 9 of the TURA planning guidance for information on the different types of planning exceptions including the note on general exceptions: “although the above circumstances exempt facilities from planning for certain chemicals, these facilities are still required to report that these exemptions apply on the ‘The Plan Submittal Selection Form’ that must be submitted with the…TUR Report.” 

The mistake: incorrectly categorizing your chemical use.

This is a question that’s highly tied to TURA reporting. However, incorrect process characterization is an error that’s often seen by plan reviewers and can cause unnecessary headaches for your facility.

We encourage you to check these simplified definitions below or see the full explanations on page 26 of the TURA reporting guidance . OTA can also help you confirm that you’ve correctly categorized your chemical use as part of your process characterization.

  • Manufacture: create a reportable chemical or import a reportable chemical
  • Process: Incorporate a reportable chemical into a product
  • Otherwise use: use a reportable chemical in the production unit in a way that does not incorporate it into the end product

Inspiration: a fresh look at options identification can help TUR planning teams navigate previously identified barriers to implementing TUR.

Toxics use reduction planning is intended as a tool that allows facility personnel to make decisions about resource allocation and determine whether there may be untapped benefits associated with reducing the use of hazardous chemicals like: 

  • Eliminating hazards from the workplace;
  • Cutting costs associated with compliance (local, state, and federal fees);
  • Cutting costs associated with the purchase of new chemicals or disposal of waste;
  • Ensuring better product or service quality for customers; and,
  • Entering new markets or enhancing the public image of your company.

Depending on how many times your facility has participated in planning and if you’ve had a consistent team, you may feel like you’ve come to the end of all possible options for toxics use reduction. At OTA, we know that in some cases that may be the case. However, we know of toxics use reduction teams that have overcome barriers by involving outside perspectives. Perhaps if your team has revisited the same options repeatedly, it’s time to examine a new angle. 

If you’ve been focusing on the lack of perceived alternative chemicals for cleaning or degreasing, or focusing on the lack of management support for and funding for new equipment, we suggest taking a look at other options. 

  • Is your production schedule optimized to reduce inefficiencies and waste or the effort needed to clean a part? 
  • Could the part be processed differently to reduce or eliminate the chemical?
  • Have you implemented an inventory control program or taken a close look at your leak detection and spill prevention program? 
  • Has your vendor been on-site to ensure you have optimized the use of the reportable chemical?
  • Are there new techniques or methods of performing the task that uses the reportable chemical?  

Inspiration: resource conservation planning.

Resource conservation planning , which allows a company to plan every other planning cycle, could be another option if your team has completed a plan and at least two plan updates. In addition to the reduced planning frequency, we find that many companies are already looking into ways to reduce overhead such as energy and water costs. With a resource conservation plan, your facility’s efforts to reduce energy or water use would count towards your TURA planning requirements that planning cycle.